Varieties of Banking Union: Resolution Regimes and Backstops in Europe and the US

In both the EU and the US, the global financial crisis and the euro crisis triggered important changes to bank resolution frameworks. Bank resolution in both jurisdictions shares the objectives of making financial institutions resolvable without threatening financial stability, while protecting taxpayer money. But the different environments and different crisis features and experiences have led to different structures on the two sides of the Atlantic. While the US evolved towards remedying a blind spot within an already existing integrated system, Europe changed its approach from coordination to centralization.